It’s now less than three weeks to go until the gender pay reporting deadline of 4 April, when employers with 250 or more employees will have to report on the gender pay gap in their organisation. Over 2,000 employers have already reported on the government’s gender pay portal, as required under the regulations.

We’ve been monitoring the submissions made so far and it’s clear that explaining pay gap data is essential. While the raw figures are vital, the story behind gender pay gap information and employer strategies for taking action are just as important.

This is especially important for recruiters, many of whom have been brought into scope because they have to report on the PAYE agency workers on their payroll. This means that for recruiters who supply temps, their headline pay gap figure will not be a true reflection of the pay of their workforce. This could be potentially misleading for clients, candidates and others who may view recruiters’ pay gap information on the government portal.

That’s why we have been encouraging recruiters to include a narrative on their websites to explain anomalies such as this and strategies for action, as recommended in the regulations.

What to include in the narrative

This narrative is an opportunity for recruiters to give some context to the figures they have submitted. Current and new employees, candidates, clients and other stakeholders will be able to view recruiters’ pay gaps online. It’s important therefore that context is given to the data so that it properly reflects organisational values and brand. Don’t worry if you have already submitted your pay gap information - it’s possible to log back in to the government portal to add this narrative at any time.

When drafting a narrative, recruiters should consider:

• Explaining any anomalies in the data. The inclusion of temps in calculations will either increase or decrease recruitment agencies’ gender pay gap. Some agencies who have already reported have highlighted in their narrative that their clients’ agency workers are included in their pay gap data. Recruiters could also include information on the pay gap of their own staff as this will be different to the headline figure on the gender pay portal. 
• Outlining causes for pay gaps. EasyJet have already reported that their gender pay gap is 51 per cent. They have been upfront in explaining that the reason for this is because the majority of their pilots are men, something which they are trying to address. For recruiters, it could be their bonus pay which is driving the pay gap. An awareness of the drivers and an explanation will provide a helpful steer for anyone who views your pay data online. 
• Explaining strategies for closing pay gaps. This narrative is also an opportunity for recruiters to outline their policy on diversity and inclusion as well as the steps they plan to take to reduce any pay gaps. The government is not expecting businesses to address this problem overnight but they do expect that reporting will drive action. The Government Equalities Office (GEO) has produced a toolkit  on actions employers can take to close the gender pay gap.

We’ll be continuing to offer advice to members through our gender pay gap reporting FAQs section on our legal guide which includes answers to key recruitment-specific questions. Members can also listen to the webinar  we hosted with the GEO.

At our next Inclusive Recruitment Forum on 17 April, we’ll be joined by the Equality and Human Rights Commission to discuss the steps recruiters can take to reduce the gender pay gap and use the data to inform clients. To register your attendance, visit our events pages.